causation standard (Georgia) · Go Syfert
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causation standard in Georgia

18 Georgia opinions name it 2 courts 1902–2025 5 in the last five years

The cases below were cited by Georgia courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (19)

CaseFollowedCited
State v. Jacksongreen
ga · 2010 · cited in 3 Georgia opinions naming this issue, 2018–2024
2 sentences

2024From Durden v. State, 250 Ga. 325, 329 (5) ( 297 SE2d 237 ) (1982), and Jones v. State, 220 Ga. 899 , 902 (3) ( 142 SE2d 801 ) (1965), we cobbled together a causation standard that we described as applicable “[i]n the context of this case”: In the context of this case, proximate causation would ex- ist if (to use “the rule” for felony murder that the Court stated a year after deciding Crane) the felony the defendants committed “directly and materially contributed to the happening of a subsequent accruing immediate cause 14 of the death,” Durden, 250 Ga. at 329 , or if (to use language from a c

2024From Durden v. State, 250 Ga. 325, 329 (5) (297 SE2d 237) (1982), and Jones v. State, 220 Ga. 899, 902 (3) (142 SE2d 801) (1965), we cobbled together a causation standard that we described as applicable “[i]n the context of this case”: 14 In the context of this case, proximate causation would ex- ist if (to use “the rule” for felony murder that the Court stated a year after deciding Crane) the felony the defendants committed “directly and materially contributed to the happening of a subsequent accruing immediate cause of the death,” Durden, 250 Ga. at 329, 297 SE2d 237, or if (to use language

33
Payne v. Stategreen
ga · 2002 · cited in 2 Georgia opinions naming this issue, 2014–2014
2 sentences

2014See Payne, supra. In addition, the Davises’ reply brief incorrectly claims that appellees did not interpose a causation defense below.

2014See Payne, supra. In addition, the Davises’ reply brief incorrectly claims that appellees did not interpose a causation defense below.

22
Skaggs v. Stategreen
ga · 2004 · cited in 3 Georgia opinions naming this issue, 2019–2024
2 sentences

2019Moreover, our review of the archived record in Skaggs shows that the causation instruction approved by this Court, see Skaggs , 278 Ga. at 22 , 596 S.E.2d 159 , and given in Skaggs was virtually identical to the language used by the trial court in this case.

2019Moreover, our review of the archived record in Skaggs shows that the causation instruction approved by this Court, see Skaggs , 278 Ga. at 22 , 596 S.E.2d 159 , and given in Skaggs was virtually identical to the language used by the trial court in this case.

13
Hill v. Stategreen
ga · 2025 · cited in 1 Georgia opinions naming this issue, 2025–2025
2 sentences

2025To show clear and obvious error, the defendant must identify “on-point controlling authority” or “the unequivocally clear words of a statute or rule that plainly establish that the trial court erred.” Hill v. State, 321 Ga. 177, 182 ( 913 SE2d 547 ) (2025) (citation and punctuation omitted).

2025To show clear and obvious error, the defendant must identify “on-point controlling authority” or “the unequivocally clear words of a statute or rule that plainly establish that the trial court erred.” Hill v. State, 321 Ga. 177, 182 ( 913 SE2d 547 ) (2025) (citation and punctuation omitted).

11
Durden v. Stategreen
ga · 1982 · cited in 1 Georgia opinions naming this issue, 2024–2024
2 sentences

2024From Durden v. State, 250 Ga. 325, 329 (5) (297 SE2d 237) (1982), and Jones v. State, 220 Ga. 899, 902 (3) (142 SE2d 801) (1965), we cobbled together a causation standard that we described as applicable “[i]n the context of this case”: 14 In the context of this case, proximate causation would ex- ist if (to use “the rule” for felony murder that the Court stated a year after deciding Crane) the felony the defendants committed “directly and materially contributed to the happening of a subsequent accruing immediate cause of the death,” Durden, 250 Ga. at 329, 297 SE2d 237, or if (to use language

2024From Durden v. State, 250 Ga. 325, 329 (5) (297 SE2d 237) (1982), and Jones v. State, 220 Ga. 899, 902 (3) (142 SE2d 801) (1965), we cobbled together a causation standard that we described as applicable “[i]n the context of this case”: 14 In the context of this case, proximate causation would ex- ist if (to use “the rule” for felony murder that the Court stated a year after deciding Crane) the felony the defendants committed “directly and materially contributed to the happening of a subsequent accruing immediate cause of the death,” Durden, 250 Ga. at 329, 297 SE2d 237, or if (to use language

11
Chaney v. Stategreen
ga · 2007 · cited in 1 Georgia opinions naming this issue, 2024–2024
2 sentences

2024See, e.g., Bell v. State, 317 Ga. 519, 522-523 (893 SE2d 918) (2023). 16 Jackson, 287 Ga, at 648-649 (2) (quoting Skaggs, 278 Ga. at 19-20 (1)); Chaney v. State, 281 Ga. 481, 482 (1) (640 SE2d 37) (2007) (same).5 That showing is ordinarily made through evidence from which a jury can infer that the forbidden result would not have hap- pened “but for” the defendant’s conduct.

2024See, e.g., Bell v. State, 317 Ga. 519, 522-523 (893 SE2d 918) (2023). 16 Jackson, 287 Ga, at 648-649 (2) (quoting Skaggs, 278 Ga. at 19-20 (1)); Chaney v. State, 281 Ga. 481, 482 (1) (640 SE2d 37) (2007) (same).5 That showing is ordinarily made through evidence from which a jury can infer that the forbidden result would not have hap- pened “but for” the defendant’s conduct.

11
Bell v. Stategreen
ga · 2023 · cited in 1 Georgia opinions naming this issue, 2024–2024
2 sentences

2024See, e.g., Bell v. State, 317 Ga. 519, 522-523 (893 SE2d 918) (2023). 16 Jackson, 287 Ga, at 648-649 (2) (quoting Skaggs, 278 Ga. at 19-20 (1)); Chaney v. State, 281 Ga. 481, 482 (1) (640 SE2d 37) (2007) (same).5 That showing is ordinarily made through evidence from which a jury can infer that the forbidden result would not have hap- pened “but for” the defendant’s conduct.

2024See, e.g., Bell v. State, 317 Ga. 519, 522-523 (893 SE2d 918) (2023). 16 Jackson, 287 Ga, at 648-649 (2) (quoting Skaggs, 278 Ga. at 19-20 (1)); Chaney v. State, 281 Ga. 481, 482 (1) (640 SE2d 37) (2007) (same).5 That showing is ordinarily made through evidence from which a jury can infer that the forbidden result would not have hap- pened “but for” the defendant’s conduct.

11
Taylor v. Stategreen
ga · 2018 · cited in 1 Georgia opinions naming this issue, 2023–2023
2 sentences

2023See Taylor v. State, 303 Ga. 624, 627 (1) ( 814 SE2d 353 ) (2018) (“Proximate cause is the causation standard for murder cases.”).

2023See Taylor v. State, 303 Ga. 624, 627 (1) ( 814 SE2d 353 ) (2018) (“Proximate cause is the causation standard for murder cases.”).

11
Georgia-Pacific, LLC v. Fieldsgreen
ga · 2013 · cited in 1 Georgia opinions naming this issue, 2022–2022
2 sentences

2022They also argue that, even if the trial court’s causation analysis was wrong, we should affirm the grant of summary judgment as right for any reason on the other grounds that they had argued to the trial court: official immunity, standing, and assumption of the risk or comparative negligence. 16 See generally Ga.-Pacific, LLC v. Fields, 293 Ga. 499, 504 (2) ( 748 SE2d 407 ) (2013) (“A grant of summary judgment must be affirmed if it is right for any reason, whether stated or unstated in the trial court’s order, so long as the movant raised the issue in the trial court and the nonmovant had a f

2022They also argue that, even if the trial court’s causation analysis was wrong, we should affirm the grant of summary judgment as right for any reason on the other grounds that they had argued to the trial court: official immunity, standing, and assumption of the risk or comparative negligence. 16 See generally Ga.-Pacific, LLC v. Fields, 293 Ga. 499, 504 (2) ( 748 SE2d 407 ) (2013) (“A grant of summary judgment must be affirmed if it is right for any reason, whether stated or unstated in the trial court’s order, so long as the movant raised the issue in the trial court and the nonmovant had a f

11
Albers v. Georgia Board of Regents of the University Systemgreen
gactapp · 2014 · cited in 1 Georgia opinions naming this issue, 2021–2021
2 sentences

2021Sys. of Ga., 330 Ga. App. 58, 62-63 (1) (b) ( 766 SE2d 520 ) (2014) (“It is true that timing may be important in the causation analysis.

2021Sys. of Ga., 330 Ga. App. 58, 62-63 (1) (b) ( 766 SE2d 520 ) (2014) (“It is true that timing may be important in the causation analysis.

11
Zywiciel v. Historic Westside Village Partners, LLCgreen
gactapp · 2011 · cited in 1 Georgia opinions naming this issue, 2020–2020
2 sentences

2020Partners, LLC, 313 Ga. App. 397, 402 (5) ( 721 SE2d 617 ) (2011); see Mordica v. State, 319 Ga. App. 149, 154-55 (2) (736 24 without a ruling by the trial court on a particular issue, there is “nothing for this Court to review upon appeal.”49 Here, as evidenced supra, Long’s motion for summary judgment as to alternative carcinogens was based solely on preventing the appellants from pursuing an apportionment defense, and the appellants acknowledge that the trial court’s sole basis for granting summary judgment was their failure to meet the causation requirement of the apportionment statute.

2020Partners, LLC, 313 Ga. App. 397, 402 (5) ( 721 SE2d 617 ) (2011); see Mordica v. State, 319 Ga. App. 149, 154-55 (2) (736 24 without a ruling by the trial court on a particular issue, there is “nothing for this Court to review upon appeal.”49 Here, as evidenced supra, Long’s motion for summary judgment as to alternative carcinogens was based solely on preventing the appellants from pursuing an apportionment defense, and the appellants acknowledge that the trial court’s sole basis for granting summary judgment was their failure to meet the causation requirement of the apportionment statute.

11
Mordica v. Stategreen
gactapp · 2012 · cited in 1 Georgia opinions naming this issue, 2020–2020
1 sentence

2020Partners, LLC, 313 Ga. App. 397, 402 (5) ( 721 SE2d 617 ) (2011); see Mordica v. State, 319 Ga. App. 149, 154-55 (2) (736 24 without a ruling by the trial court on a particular issue, there is “nothing for this Court to review upon appeal.”49 Here, as evidenced supra, Long’s motion for summary judgment as to alternative carcinogens was based solely on preventing the appellants from pursuing an apportionment defense, and the appellants acknowledge that the trial court’s sole basis for granting summary judgment was their failure to meet the causation requirement of the apportionment statute.

11
Urie v. Thompsongreen
scotus · 1949 · cited in 1 Georgia opinions naming this issue, 2013–2013
1 sentence

2013See Urie, 337 U. S. at 181 (noting that FELA’s language on causation “is as broad as could be framed”).

11
Zeagler v. Norfolk Southern Railway Co.green
gactapp · 2012 · cited in 1 Georgia opinions naming this issue, 2013–2013
1 sentence

2013See Zeagler, 317 Ga. App. at 304-306 . (d) Causation: The causation standard for a FELA claim is extremely relaxed.

11
Billingsley v. Stategreen
gactapp · 1987 · cited in 1 Georgia opinions naming this issue, 1994–1994
2 sentences

1994In Williams v. State, 165 Ga. App. 831, 832 ( 302 SE2d 736 ) (1983), we noted the importance of assuring that the jury understands "the causation requirement." NOTES [1] Compare Billingsley v. State, 183 Ga. App. 850, 853 (5) ( 360 SE2d 451 ) (1987).

1994In Williams v. State, 165 Ga. App. 831, 832 ( 302 SE2d 736 ) (1983), we noted the importance of assuring that the jury understands "the causation requirement." NOTES [1] Compare Billingsley v. State, 183 Ga. App. 850, 853 (5) ( 360 SE2d 451 ) (1987).

11
Atlanta Coca-Cola Bottling Company v. Jonesgreen
ga · 1976 · cited in 1 Georgia opinions naming this issue, 1979–1979
2 sentences

1979See Minnick v. Jackson, 64 Ga. App. 554, 556-558 ( 13 SE2d 891 ); Atlanta Coca-Cola Bottling Co. v. Jones, 236 Ga. 448, 451 ( 224 SE2d 25 ); Sikes v. Norris, 99 Ga. App. 351, 358 ( 108 SE2d 192 ); Padgett v. Central of Ga. R.

1979See Minnick v. Jackson, 64 Ga. App. 554, 556-558 ( 13 SE2d 891 ); Atlanta Coca-Cola Bottling Co. v. Jones, 236 Ga. 448, 451 ( 224 SE2d 25 ); Sikes v. Norris, 99 Ga. App. 351, 358 ( 108 SE2d 192 ); Padgett v. Central of Ga. R.

11
Minnick v. Jacksongreen
gactapp · 1941 · cited in 1 Georgia opinions naming this issue, 1979–1979
2 sentences

1979See Minnick v. Jackson, 64 Ga. App. 554, 556-558 ( 13 SE2d 891 ); Atlanta Coca-Cola Bottling Co. v. Jones, 236 Ga. 448, 451 ( 224 SE2d 25 ); Sikes v. Norris, 99 Ga. App. 351, 358 ( 108 SE2d 192 ); Padgett v. Central of Ga. R.

1979See Minnick v. Jackson, 64 Ga. App. 554, 556-558 ( 13 SE2d 891 ); Atlanta Coca-Cola Bottling Co. v. Jones, 236 Ga. 448, 451 ( 224 SE2d 25 ); Sikes v. Norris, 99 Ga. App. 351, 358 ( 108 SE2d 192 ); Padgett v. Central of Ga. R.

11
City of Jefferson v. Maddoxgreen
gactapp · 1967 · cited in 1 Georgia opinions naming this issue, 1979–1979
2 sentences

1979City of Jefferson v. Maddox, 116 Ga. App. 51, 55 (6) ( 156 SE2d 553 ); Worn v. Sea-Cold Services, 135 Ga. App. 256 (2), supra. As the causation factors here were in controversy, the trial court did not err in denying the defendants’ motions for directed verdict or for judgment notwithstanding the verdict and in denying the motion for new trial based on the general grounds.

1979City of Jefferson v. Maddox, 116 Ga. App. 51, 55 (6) ( 156 SE2d 553 ); Worn v. Sea-Cold Services, 135 Ga. App. 256 (2), supra. As the causation factors here were in controversy, the trial court did not err in denying the defendants’ motions for directed verdict or for judgment notwithstanding the verdict and in denying the motion for new trial based on the general grounds.

11
Sikes v. Norrisgreen
gactapp · 1959 · cited in 1 Georgia opinions naming this issue, 1979–1979
2 sentences

1979See Minnick v. Jackson, 64 Ga. App. 554, 556-558 ( 13 SE2d 891 ); Atlanta Coca-Cola Bottling Co. v. Jones, 236 Ga. 448, 451 ( 224 SE2d 25 ); Sikes v. Norris, 99 Ga. App. 351, 358 ( 108 SE2d 192 ); Padgett v. Central of Ga. R.

1979See Minnick v. Jackson, 64 Ga. App. 554, 556-558 ( 13 SE2d 891 ); Atlanta Coca-Cola Bottling Co. v. Jones, 236 Ga. 448, 451 ( 224 SE2d 25 ); Sikes v. Norris, 99 Ga. App. 351, 358 ( 108 SE2d 192 ); Padgett v. Central of Ga. R.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Georgia. Read the followed side critically anyway.

Also cited on this issue (6)

CaseCitedYears
Jones v. State green
ga · 1965
2 sentences

2024From Durden v. State, 250 Ga. 325, 329 (5) (297 SE2d 237) (1982), and Jones v. State, 220 Ga. 899, 902 (3) (142 SE2d 801) (1965), we cobbled together a causation standard that we described as applicable “[i]n the context of this case”: 14 In the context of this case, proximate causation would ex- ist if (to use “the rule” for felony murder that the Court stated a year after deciding Crane) the felony the defendants committed “directly and materially contributed to the happening of a subsequent accruing immediate cause of the death,” Durden, 250 Ga. at 329, 297 SE2d 237, or if (to use language

2024From Durden v. State, 250 Ga. 325, 329 (5) (297 SE2d 237) (1982), and Jones v. State, 220 Ga. 899, 902 (3) (142 SE2d 801) (1965), we cobbled together a causation standard that we described as applicable “[i]n the context of this case”: 14 In the context of this case, proximate causation would ex- ist if (to use “the rule” for felony murder that the Court stated a year after deciding Crane) the felony the defendants committed “directly and materially contributed to the happening of a subsequent accruing immediate cause of the death,” Durden, 250 Ga. at 329, 297 SE2d 237, or if (to use language

12024–2024
Norfolk Southern Railway Co. v. Schumpert green
gactapp · 2004
2 sentences

2017Co. v. Schumpert , 270 Ga. App. 782 , 784 (1), 608 S.E.2d 236 (2004).

2017Co. v. Schumpert , 270 Ga. App. 782 , 784 (1), 608 S.E.2d 236 (2004).

12017–2017
Pitts v. State green
gactapp · 2002
1 sentence

2012The language in question is taken from Pitts v. State, 253 Ga. *863 App. 373, 374 (1) ( 559 SE2d 106 ) (2002), a vehicular homicide case.

12012–2012
Williams v. State green
gactapp · 1983
2 sentences

1994In Williams v. State, 165 Ga. App. 831, 832 ( 302 SE2d 736 ) (1983), we noted the importance of assuring that the jury understands "the causation requirement." NOTES [1] Compare Billingsley v. State, 183 Ga. App. 850, 853 (5) ( 360 SE2d 451 ) (1987).

1994In Williams v. State, 165 Ga. App. 831, 832 ( 302 SE2d 736 ) (1983), we noted the importance of assuring that the jury understands "the causation requirement." NOTES [1] Compare Billingsley v. State, 183 Ga. App. 850, 853 (5) ( 360 SE2d 451 ) (1987).

11994–1994
Worn v. Sea-Cold Services, Inc. green
gactapp · 1975
1 sentence

1979City of Jefferson v. Maddox, 116 Ga. App. 51, 55 (6) ( 156 SE2d 553 ); Worn v. Sea-Cold Services, 135 Ga. App. 256 (2), supra. As the causation factors here were in controversy, the trial court did not err in denying the defendants’ motions for directed verdict or for judgment notwithstanding the verdict and in denying the motion for new trial based on the general grounds.

11979–1979
Pullman Palace Car Co. v. Barker neutral
colo · 1878
1 sentence

1902As was said by Elbert, J., in Pullman Palace Car Co. v. Barker, 4 Colo. 344 , “ What is the proximate cause of an injury in a legal sense is often an embarrassing question, involved in metaphysical distinctions and subtleties difficult of satisfactory application in the varied and prac tieal affairs of life.” Chief Justice Shaw, in Marble v. Worcester, 4 Gray, 397 , said: “The whole doctrine of causation, considered in itself metaphysically, is of profound difficulty, even if it may not be said of mystery.” In Scott v. Hunter, 46 Penn.

11902–1902

Statutes the citing opinions construe

GA § 16-5-1 (7) GA § 9-11-56 (4)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

TX 254 (1978–2026) CA 164 (1978–2026) PA 61 (1952–2026) IL 50 (1980–2026) IA 49 (1982–2024) MI 49 (1988–2026) MO 42 (1989–2024) OH 35 (1991–2025) UT 30 (1986–2026) MA 29 (1980–2025) OR 28 (1990–2024) AL 27 (1964–2025) NY 27 (1933–2024) MD 26 (1977–2022) MN 26 (1987–2026) LA 25 (1984–2021) NM 23 (1938–2024) CT 23 (1991–2026) WA 22 (1983–2023) FL 21 (1984–2025) NJ 20 (1990–2026) WI 19 (1995–2024) GA 18 (1902–2025) SD 16 (1992–2020) VA 14 (1988–2025) AZ 13 (1997–2024) CO 13 (1984–2020) TN 13 (1997–2019) ID 12 (2005–2026) AK 12 (1988–2022) DC 12 (1990–2024) NC 11 (1918–2020) HI 11 (1995–2026) IN 10 (1986–2011) MT 10 (1990–2022) VT 10 (1991–2024) RI 9 (1993–2026) KS 9 (1991–2025) WY 8 (1982–2013) NE 8 (1996–2026) ME 8 (1982–2021) MS 7 (1992–2011) NH 7 (1986–2021) AR 6 (1999–2025) DE 4 (2014–2024) NV 3 (2012–2026) OK 3 (1981–2026) KY 3 (2006–2026) ND 2 (1994–2010) WV 2 (1997–2001)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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